Seaboard Coast Line Railroad v. Blackmon

Quillian, Judge.

This is an appeal by Seaboard Coast Line Railroad Company (hereinafter referred to as Seaboard) from a judgment of the Fulton Superior Court sustaining an assessment made against Seaboard by the State Revenue Commissioner (hereinafter referred to as Commissioner) for additional income taxes found by the Commissioner to be due for the taxable year ending December 31, 1969. The trial judge denied Seaboard’s motion for summary judgment and granted the Commissioner’s motion for summary judgment.

Simply stated, in 1968 Seaboard lost money and in 1969 it made money. The issue here…